Michael M. v. Superior Court of Sonoma County

In the popular perception, rape is a crime most often between strangers: for instance, a lone woman is walking down a dark alley, where she is accosted by an assailant she has never seen before and will never see again unless he is caught.

This view, however pervasive it may be, is inaccurate, as has become clear through increasing societal awareness of date rape and acquaintance rape--not to mention Department of Justice statistics, which show that the majority of rape victims knew their assailants. One 1994 Justice Department study, for example, showed that of all types of crime studied, rape had the highest percentage of incidents involving non-strangers: 77 percent. By contrast, figures were as low as 18 percent for completed robbery without injury, meaning that in 82 percent of all such crimes reported, the victim did not know the perpetrator.

Another Justice Department study offered some information on relationship of victims to the perpetrator. Though in a third of instances, the data showed only that the rapist was well-known to the victim without specifying relationship. Ten percent of rapes, according to this study, were committed by spouses, ex-spouses, or other relatives.